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The policy states that the service is not directed at users under 13, that Modal Labs does not knowingly collect personal information from children under 13, and that upon discovery such information will be immediately deleted; parents or guardians may contact the company to request action.
This analysis describes what Modal's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
This provision reflects a standard COPPA-aligned disclosure for services not directed at children. The policy does not provide a specific contact address for parental requests, which may create a practical barrier to exercising the stated deletion right.
Under this clause, personal information submitted by children under 13 is subject to deletion upon discovery, and parents or guardians may contact Modal Labs to initiate that process, though no specific contact method or address is identified in the document.
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"Our Services do not address anyone under the age of 13. We do not knowingly collect personal identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.Excerpt from Modal's Privacy Policy
(1) REGULATORY LANDSCAPE: This provision engages COPPA, which requires operators of websites not directed at children to delete personal information collected from children under 13 upon discovery. The policy's language is consistent with COPPA's general requirements. The FTC enforces COPPA. (2) GOVERNANCE EXPOSURE: Low. The provision is consistent with standard COPPA disclosure practice for general-audience platforms. The absence of a specific contact address for parental requests is a minor gap. (3) JURISDICTION FLAGS: COPPA applies to operators of websites directed to children or that have actual knowledge of collecting personal information from children under 13 in the United States. EU and UK platforms may have additional obligations under GDPR and the UK Age Appropriate Design Code regarding processing of children's data. (4) CONTRACT AND VENDOR IMPLICATIONS: No material vendor or contract implications arise from this provision beyond standard COPPA compliance posture. (5) COMPLIANCE CONSIDERATIONS: Compliance teams should verify that a specific parental contact mechanism exists and is accessible, and should evaluate whether the platform's user verification procedures are sufficient to prevent collection of data from children under 13.
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This provision reflects a standard COPPA-aligned disclosure for services not directed at children. The policy does not provide a specific contact address for parental requests, which may create a practical barrier to exercising the stated deletion right.
Under this clause, personal information submitted by children under 13 is subject to deletion upon discovery, and parents or guardians may contact Modal Labs to initiate that process, though no specific contact method or address is identified in the document.
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